G.R. No. 255703, October 23, 2024
People of the Philippines, Plaintiff-Appellee, vs. Sim O. Mata, Jr., Accused-Appellant.

FACTS

Accused-appellant Sim O. Mata, Jr., the Provincial Legal Officer of Camarines Norte, along with Governor Edgardo A. Tallado and Supervising Administrative Officer Mario T. Dela Cruz, were charged with violation of Section 3(e) of R.A. No. 3019. The Information alleged that they conspired to cause undue injury to Provincial Veterinarian Edgardo S. Gonzales by ignoring Civil Service Commission (CSC) orders directing Gonzales’s reinstatement to the Provincial Veterinary Office (PVO) and by subsequently dropping him from the rolls. The case stemmed from Governor Tallado’s Memorandum No. 120301-06, dated March 1, 2012, which reassigned Dr. Gonzales to the Provincial Information Office (PIO). Dr. Gonzales appealed to the CSC, which, in Decision No. 120494 dated August 9, 2012, nullified the reassignment as violative of R.A. No. 7305 (Magna Carta of Public Health Workers) and directed Tallado to immediately return Gonzales to the PVO. Mata advised Tallado not to implement the CSC decision, arguing it was not immediately executory, and recommended filing a motion for reconsideration and a subsequent petition for certiorari, which were ultimately denied. Despite evidence that Dr. Gonzales reported for work (as shown by his daily time records and letters from March to November 2012), Mata, acting on a report that Gonzales was absent from his PIO post, recommended that Tallado drop Gonzales from the rolls. Tallado issued Memorandum No. 121119-02 on November 19, 2012, dropping Gonzales for being AWOL. The CSC, in Decision No. 130841 dated August 12, 2013, nullified this dropping from the rolls and directed Gonzales’s restoration with back salaries. Dr. Gonzales was not reinstated to the PVO until his retirement on December 11, 2015, resulting in unpaid salaries and benefits. The Sandiganbayan convicted Mata but acquitted Tallado and Dela Cruz.

ISSUE

Whether the Sandiganbayan correctly found accused-appellant Sim O. Mata, Jr. guilty beyond reasonable doubt of violating Section 3(e) of R.A. No. 3019.

RULING

Yes, the Sandiganbayan correctly convicted Mata. The Court affirmed the Sandiganbayan’s finding that Mata, as Provincial Legal Officer, acted with evident bad faith, causing undue injury to Dr. Gonzales. Mata gave unsound legal advice contrary to explicit rules: (1) he advised non-implementation of the immediately executory CSC Decision No. 120494, despite the Revised Rules on Administrative Cases in the Civil Service providing that CSC rulings are immediately executory unless restrained by a higher court; and (2) he recommended dropping Gonzales from the rolls for being AWOL despite evidence directly contradicting the claim of absence. These acts constituted evident bad faith in the discharge of his administrative functions as a public officer. The injury to Dr. Gonzales was quantified at PHP 714,168.00 in unpaid salaries and benefits. The Court upheld the penalty imposed by the Sandiganbayan: imprisonment for an indeterminate period of six years and one month, as minimum, to ten years, as maximum, and perpetual disqualification from holding public office. The acquittals of Tallado and Dela Cruz were not disturbed.